JHK Enterprises, Inc., A California Corporation - Page 13




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          lease office space and equipment from petitioner.  Petitioner               
          reported gross receipts in the amount of $266,072 for 1995.  This           
          is an increase from petitioner’s reported gross receipts in the             
          amount of $94,000 for 1994.  Petitioner failed to reconcile its             
          increase in gross receipts with its claim to have suffered                  
          devastating adverse impacts from Kaufman’s suspension.                      
               As evidence of petitioner’s abandonment of tangible assets,            
          petitioner provided a document entitled “JHK Enterprises                    
          Equipment Schedule as of 12/1/96” (the equipment schedule).  The            
          equipment schedule is a list of tangible assets.  Some of the               
          assets are listed as “In Service”, others as “Abandoned”, and               
          still others as “1/2 Abandoned 1/2 In Service”.  The equipment              
          schedule does not list a date of abandonment or a method of                 
          abandonment for any asset.  The equipment schedule does not                 
          reflect that petitioner abandoned any tangible asset during 1995.           
          At most, it reflects that petitioner abandoned some tangible                
          assets before December 1, 1996.                                             
               Petitioner has not established that it abandoned any                   
          tangible asset in 1995.  Aside from self-serving testimony of               
          petitioner’s president, petitioner has not provided any evidence            
          that it abandoned tangible assets during 1995.                              
               Assuming, for the sake of argument, that petitioner                    
          abandoned tangible assets during 1995, petitioner’s loss                    
          deduction would be limited to its adjusted basis in the abandoned           






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